Full Privacy Statement
This privacy statement applies to www.EquiSeq.com owned and operated by EquiSeq Inc. Our Privacy Statement is designed to help you better understand how we collect, use, store, process, and transfer your information when operating our website, mobile apps, products, software and other services (collectively "Service" or "Services")
- Key Definitions
- What information we collect
- Information you provide directly to us
- Information related to our genetic testing Services
- Information collected through tracking technology
- Other types of information
- How we use and share information
- Using information to provide, analyze and improve our Services
- Using information with your consent
- Recruiting for external research
- Information we share with third-parties
- Disclosures required by law
- Your choices
- Access to your account
- Marketing communications
- Information you choose to share with others
- Account Closure
- Important Information
- Safe Harbor
- Security Measures
- Business Transactions
- Linked Websites
- Children's Privacy
- Changes to this Privacy Statement
- Contact information
1. Key Definitions
Aggregate Information: information that has been combined with that of other users and analyzed or evaluated as a whole, such that no specific individual may be reasonably identified.
Anonymized Information: information that has been stripped of your Registration Information (e.g., your name and contact information) and other identifying data such that you cannot reasonably be identified as an individual.
Individual-level Information: information about a single horse's genotypes, diseases or other traits/characteristics, but which is not necessarily tied to Registration Information.
Personal Information: information that can be used to identify you, either alone or in combination with other information. EquiSeq collects and stores the following types of Personal Information:
Registration Information: information you provide about yourself when registering for and/or purchasing our Services (e.g. name, email, address, user ID and password, and payment information).
Genetic Information: information regarding your horse's genotype (e.g. the As, Ts, Cs, and Gs at particular locations in your horse's genome), generated through processing of hair, blood, or tissue samples by EquiSeq or by its contractors, successors, or assignees; or otherwise processed by and/or contributed to EquiSeq.
Self-Reported Information: all information about your horse, including disease conditions, other health-related information, performance traits, breed, pedigree, and other information that you enter into surveys, forms, or features while signed in to your EquiSeq account.
Sensitive Information: information about your horse's health, Genetic Information, and certain Self-Reported Information such as breed and pedigree.
User Content: all information, data, text, software, music, audio, photographs, graphics, video, messages, or other materials - other than Genetic Information and Self-Reported Information-generated by users of EquiSeq Services and transmitted, whether publicly or privately, to or through EquiSeq.
Web Behavior Information: information on how you use the EquiSeq website (e.g. browser type, domains, page views) collected through log files, cookies, and web beacon technology.
Service or Services: EquiSeq's products, software, services, and website (including but not limited to text, graphics, images, and other material and information) as accessed from time to time by the user, regardless if the use is in connection with an account or not.
The following are our core privacy principles:
We collect and handle information (i) to provide, analyze and improve our Services, (ii) as we reasonably believe is permitted by laws and regulations, including for marketing and advertising purposes, (iii) to protect the security and safety of our company, employees, customers, as we reasonably believe is permitted by laws and regulations, (iv) to comply with laws and regulations we are subject to, and (v) when you consent, for research purposes, the results of which could be used to develop therapeutics.
We will not sell, lease, or rent your individual-level information (i.e., information about a single individual's genotypes, diseases, or other traits/characteristics) to any third-party or to a third-party for research purposes without your explicit consent.
We understand and respect the sensitive nature of the information you may provide to us, including information about your horse's genetic characteristics, disease conditions, breed and pedigree, etc. To that end, we strive to be transparent in our collection, use and disclosure of this information and to ask for your explicit consent to share such sensitive information with third-parties. Please see below to learn more about our sharing and consent practices.
We are committed to providing a secure and safe environment for our Services.
Please review this Privacy Statement and our Terms of Service. By using our Services, you agree to all of the policies and procedures described in the foregoing documents. EquiSeq is headquartered at 725 6th Street NW, Albuquerque, NM 87102 and is referred to herein as EquiSeq (or "we," "us," "our") and includes all of our commonly owned companies.
3. What information we collect
Information you provide directly to us
Registration Information. When you register an account with us or purchase our Services, we collect personal information, such as your name, billing and shipping address, payment information (e.g., credit card) and contact information such as your email and phone number.
Self-Reported Information. You have the option to provide us with additional information about your horse through surveys, forms, features or applications. For example, you may provide us with information about your horse's traits (e.g., coat color, height), breed, disease conditions (e.g. PSSM), other health-related information (e.g. weight, blood chemistry, response to exercise), and pedigree information (e.g. information similar to the foregoing about horses related to your horse). Where you are disclosing information about a related horse, you should make sure that you have permission from the owner to do so.
Social Media Features and Widgets. Our website includes Social Media Features, such as the Facebook Like or Share button and Widgets, and the LinkedIn Open ID application ("Features"). These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. They may also allow third-party social media services to provide us information about you, including your name, email address, and other contact information. For example, if you use LinkedIn to sign in to our career portal, LinkedIn may import personal information from your LinkedIn profile in order to populate your job application. The data we receive is dependent upon your privacy settings with the social network. Features are either hosted by a third-party or hosted directly on our site. Your interactions with these Features are governed by the privacy statement of the company providing it. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to our website or Service.
Referral Information and Sharing. When you refer a person to EquiSeq or choose to share results information with another person, we will ask for that person's email address. We will use the email address solely, as applicable, to make the referral or to share your results information. By participating in a referral program or by choosing to share information with another person, you confirm that the person has given you consent for EquiSeq to communicate (e.g., via email) with him or her. The person you referred may contact us to request that we remove this information from our database.
Address books. If you choose to use your computer's or mobile device's address book in connection with our Services to make referrals or to request that we communicate with another person, we may collect the names and contact information of those persons for these purposes only.
Third-party services (e.g., social media). If you use a third-party site, such as Facebook or Twitter, in connection with our Services to communicate with another person (e.g., to make or post referrals or to request that we communicate with another person), then in addition to that person's name and contact information, we may also collect other information (e.g., your profile picture, network, gender, username, user ID, age range, language, country, friends lists or followers) depending on your privacy settings on the third-party site. We do not control third-party site's information practices, so please review their privacy policies and your settings on those sites carefully.
Gifts. If you provide us personal information about others, or if others give us your information for purposes of ordering the Service as a gift, we will only use that information for the specific reason for which it was provided to us. Once a gift recipient registers for his or her Services and agrees to our Privacy Statement, our Terms of Service, and if applicable, Consent Document, his or her information will be used consistent with this Privacy Statement and those agreements, and we will not share any of the gift recipient's personal information with the user who purchased the gift.
Customer service. When you contact our Customer Care center or correspond with us about our Service, we collect information to: track and respond to your inquiry; investigate any breach of our Terms of Service, Privacy Statement or applicable laws or regulations; and analyze and improve our Services.
Information related to our genetic testing services
To use our genetic testing services, you must purchase, or receive as a gift, a test, register an online account, and ship your hair, blood, or other tissue sample to our third-party laboratory. Once received, your horse's sample will be identified by its unique code, along with your horse's gender and year of birth. The label identifies you to us but not to our third-party laboratory. Unless you choose to store your sample with EquiSeq, your samples and DNA are destroyed after the laboratory completes its work, unless the laboratory's legal and regulatory requirements require it to maintain physical samples.
Genetic Information. Genetic Information refers to features of your horse's DNA that distinguish your horse from other horses (e.g. the As, Ts, Cs, and Gs at particular locations in your horse's genome) and is generated when we analyze and process your hair, blood, or tissue sample, or when you otherwise contribute or access your horse's Genetic Information through our Services. Genetic Information includes the EquiSeq Results information reported to you as part of our Services, and may be used for other purposes, as outlined in Section 4 below. Information collected through tracking technology (e.g. from cookies and similar technologies)
As is true of most websites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We may combine this automatically collected log information with other information we collect about you, such as your user profile ID or order number. We do this to improve services we offer you, and to improve marketing, analytics, and site functionality.
When you access our Service by or through a mobile device, we may receive or collect and store a unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers ("IDFA"), Google Ad ID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude) or similar information regarding the location of your mobile device.
Other Types of Information.
We are always working to enhance our Services with new products, applications and features that may result in the collection of new and different types of information. We will update our privacy statement, as needed.
4. How we use and share information
EquiSeq will use and share your personal information with third-parties only in the ways that are described in this privacy statement.
Using information to provide, analyze and improve our Services
We use the information described above in Section 3 to operate, provide, analyze and improve our Services. These activities may include, among other things, using your information in a manner consistent with other commitments in this privacy statement, to:
open your account, enable purchases and process payments, communicate with you, and implement your requests (e.g., referrals);
host our website, run our mobile application(s), authenticate your visits, provide custom, personalized content and information, and track your usage of our Services;
conduct analytics to improve and enhance our Services;
offer new products or services to you, including through emails, promotions or contests;
implement online marketing campaigns and targeted advertising, including by utilizing third-party ads (subject to your cookie settings and preferences), and to measure the effectiveness of our marketing and targeted advertising;
conduct surveys or polls, and obtain testimonials;
process and deliver your genetic testing results;
perform research & development activities, which may include, for example, conducting data analysis and research in order to develop new or improve existing products and services, and performing quality control activities.
You may be able to opt-in, opt-out or otherwise adjust your preferences of having your information used for certain of these activities. Please see below to learn more.
Using information with your consent
You have the choice to participate in EquiSeq Research by providing your consent. "EquiSeq Research" refers to research aimed at publication in peer-reviewed journals and other research funded by the federal government (such as the National Institutes of Health - NIH) conducted by EquiSeq. EquiSeq Research may be sponsored by, conducted on behalf of, or in collaboration with third-parties, such as non-profit foundations, academic institutions or pharmaceutical companies. EquiSeq Research may study a specific breed or population, identify potential areas or targets for therapeutics development, conduct or support the development of drugs, diagnostics or devices to diagnose, predict or treat medical or other health conditions, work with public, private and/or non-profit entities on genetic research initiatives, or otherwise create, commercialize, and apply this new knowledge to improve veterinary care. EquiSeq Research uses your horse's aggregate or individual-level Genetic Information and Self-Reported Information as specified in the Consent Document.
Consent process for research. Your Genetic and Self-Reported Information may be used for EquiSeq Research only if you have consented to this use by completing a Consent Document. If you have completed a Consent Document:
EquiSeq may use individual-level Genetic Information and Self-Reported Information internally at EquiSeq for Research purposes. In addition, we may allow select third-party research contractors to access your horse's individual level Genetic and/or Self-Reported Information onsite at EquiSeq's offices for the purpose of conducting scientific research, provided that all such research contractors will be supervised by EquiSeq and subject to EquiSeq's access rules and guidelines.
When your horse's Genetic Information and/or Self-Reported Information is being used for research purposes, it will not be linked to your Registration Information.
Withdrawing your Consent.
You may withdraw your consent to participate in Research at any time by sending a request to firstname.lastname@example.org. EquiSeq will not include your Genetic Information or Self-Reported Information in new research occurring after 30 days from the receipt of your request. Any research involving your data that has already been performed or published prior to our receipt of your request will not be reversed, undone, or withdrawn. If you withdraw your consent for research your Genetic Information and Self-Reported Information may still be used by us and shared with our third-party service providers to provide and improve our Services (as described in Section 4.a), and shared as Aggregate Information that does not identify you as an individual (as described in Section 4.d).
What happens if you do NOT consent to EquiSeq Research?
If you do not complete a Consent Document or any additional consent agreement with EquiSeq, your information will not be used for EquiSeq Research. However, your horse's Genetic Information and Self-Reported Information may still be used by us and shared with our third-party service providers to provide and improve our Services (as described in Section 4.a), and shared as Aggregate or Anonymous Information that does not reasonably identify you as an individual (as described in Section 4.d).
Recruiting for external research
Academic institutions, healthcare organizations, and other groups are always conducting interesting new research projects. We want to make you aware of these opportunities. While we do not share individual-level Genetic Information or Self-Reported Information with third-parties without your consent, from time to time we may inform you of third-party research opportunities for which your horse may be eligible. For example, if a university tells us about a new laminitis research project, we may send an email to EquiSeq members whose horses potentially fit the relevant eligibility criteria based on their Self-Reported Information to make them aware of the research project and provide a link to participate with the research organization conducting the study.
Information we share with third-parties
General service providers. We share the information described above in Section 3 with our service providers, as necessary to provide their services to us. Service providers are third-parties (other companies or individuals) that help us to provide, analyze and improve our Services. For example, we work with third-party laboratories and contractors to process and analyze your saliva sample for purposes of generating your Genetic Information.
NOTE: Our service providers act on EquiSeq's behalf. While we implement procedures and contractual terms to protect the confidentiality and security of your information, we cannot guarantee the confidentiality and security of your information due to the inherent risks associated with storing and transmitting data electronically.
Aggregate information. We may share aggregate information with third-parties, which is any information that has been stripped of your Registration Information (e.g., your name and contact information) and aggregated with information of others so that you cannot reasonably be identified as an individual ("Aggregate Information"). This Aggregate Information is different from "individual-level" information. Individual-level Genetic Information or Self-Reported Information consists of data about a single individual's genotypes, diseases or other traits/characteristics information. For example, Aggregate Information may include a statement that "30% of our mares share a particular genetic trait," without providing any data or testing results specific to any individual user. We may provide such Aggregate Information in commercial arrangements with our business partners. In contrast, individual-level Genetic Information could reveal whether a specific horse has a particular genetic trait, or all of the Genetic Information about that horse. EquiSeq will ask for your consent to share individual-level Genetic Information or Self-Reported Information with any third-party, other than our service providers as necessary for us to provide the Services to you.
Information we share with commonly owned entities. We may share some or all of your information with other companies under common ownership or control of EquiSeq, which may include our subsidiaries, our corporate parent, or any other subsidiaries owned by our corporate parent in order to provide you better service and improve user experience. We may provide additional notice and ask for your consent if we wish to share your information with our commonly owned entities in a materially different way than discussed in this Privacy Statement.
Disclosures required by law
Under certain circumstances your information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders, or in coordination with regulatory authorities. EquiSeq will preserve and disclose any and all information to law enforcement agencies or others if required to do so by law or in the good faith belief that such preservation or disclosure is reasonably necessary to: (a) comply with legal or regulatory process (such as a judicial proceeding, court order, or government inquiry) or obligations that EquiSeq may owe pursuant to ethical and other professional rules, laws, and regulations; (b) enforce the EquiSeq Terms of Service and other policies; (c) respond to claims that any content violates the rights of third-parties; or (d) protect the rights, property, or personal safety of EquiSeq, its employees, its users, its clients, and the public.
5. Your choices
Access to your account
If your Registration Information changes, you may access, correct or update most of it from your Account Settings page. You may also modify and delete certain of your information, or update your consent status. You may be able to correct or reset Self-Reported Information entered into a survey, form, or feature from your account on the surveys page. Please note that you may not be able to delete User Content that has been shared with others through the Service and that you may not be able to delete information that has been shared with third-parties, though we can work with you to prohibit your data from being shared with third-parties in the future. We will respond to your request to access within 30 days.
By registering for an account, you are agreeing that we may send you promotional emails about our Services. You can opt-out of receiving certain messages or notifications from us by visiting your Account page (go to Account, Settings, Notifications) or by contacting our Privacy Administrator at email@example.com. You can also click the "unsubscribe" button at the bottom of promotional email communications. Please note that you may not opt-out of receiving non-promotional messages regarding your account, such as technical notices, purchase confirmations, or Service-related emails.
For more information about our online advertising, please also refer to Section 4.d.ii above under the heading "Targeted Advertising Service Providers."
Information you choose to share with others
EquiSeq gives you the ability to share information with other individuals who have EquiSeq accounts through sharing features (such information is "User Content"). Please refer to your settings. You may be required to opt-in to some of this sharing, but some features require an opt-out. You may opt-out or change the visibility of your horse's profile data by visiting your Settings. Also, please note that certain types of your User Content may be viewable by other EquiSeq users and once posted, you may not be able to delete or modify such content.
You may decide to disclose your horse's information to friends and/or family members, veterinarians or other health care professionals, and/or other individuals outside of our Services, including through third-party services such as social networks and third-party apps that connect to our website and mobile apps through our application programming interface ("API"). These third-parties may use your personal information differently than we do under this Privacy Statement. Please make such choices carefully and review the privacy policies of all other third-parties involved in the transaction. For example, if you have enabled a EquiSeq sharing feature with another person who downloads a third-party app that uses our API, your information may also be obtained by that third-party app developer and, potentially, by other users of that third-party app.
In general, personal information, once shared or disclosed, can be difficult to contain or retrieve. EquiSeq will have no responsibility or liability for any consequences that may result because you have released or shared personal information with others.
If you no longer wish to participate in our Services or no longer wish to have your personal information be used, you may close your account by sending a request to Customer Care. When closing an account, we remove all Genetic Information within your account (or profile) within thirty (30) days of our receipt of your request. As stated in any applicable Consent Document, however, Genetic Information and/or Self-Reported Information that you have previously provided and for which you have given consent to use in EquiSeq Research cannot be removed from ongoing or completed studies that use the information. Our contracted genotyping laboratory may also retain your Genetic Information as required by local law and we may retain backup copies for a limited period of time pursuant to our data protection policies. In addition, we retain limited Registration Information related to your order history (e.g., name, contact, and transaction data) as long as your account is active or as needed to provide you services, as well as for accounting, audit and compliance purposes.
6. Important Information
EquiSeq takes seriously the trust you place in us. To prevent unauthorized access or disclosure, to maintain data accuracy, and to ensure the appropriate use of information, EquiSeq uses a range of physical, technical, and administrative measures to safeguard your Personal Information. In particular, all connections to and from our website and mobile application are encrypted using Secure Socket Layer (SSL) technology.
Please recognize that protecting your Personal Information is also your responsibility. We ask you to be responsible for safeguarding your password, secret questions and answers, and other authentication information you use to access our Services. You should not disclose your authentication information to any third-party and should immediately notify EquiSeq of any unauthorized use of your password. EquiSeq cannot secure Personal Information that you release on your own or that you request us to release.
Your information collected through the Service may be stored and processed in the United States or any other country in which EquiSeq or its subsidiaries, affiliates or service providers maintain facilities and, therefore, your information may be subject to the laws of those other jurisdictions which may be different from the laws of your country of residence.
In the event that EquiSeq goes through a business transition such as a merger, acquisition by another company, or sale of all or a portion of its assets, your information will likely be among the assets transferred. In such a case, your information would remain subject to the promises made in any pre-existing Privacy Statement.
EquiSeq provides links to third-party websites operated by organizations not affiliated with EquiSeq. EquiSeq does not disclose your information to organizations operating such linked third-party websites. EquiSeq does not review or endorse, and is not responsible for, the privacy practices of these organizations. We encourage you to read the privacy statements of each and every website that you visit. This Privacy Statement applies solely to information collected by EquiSeq.
EquiSeq is committed to protecting the privacy of children as well as adults. Neither EquiSeq nor any of its Services are designed for, intended to attract, or directed toward children under the age of 13.
Changes to this Privacy Statement
Whenever this Privacy Statement is changed in a material way, a notice will be posted as part of this Privacy Statement and on our customers' account login pages for 30 days. After 30 days the changes will become effective. In addition, all customers will receive an email with notification of the changes prior to the change becoming effective.
7. Contact Information
If you have questions about this Privacy Statement, please email EquiSeq's Privacy Administrator at firstname.lastname@example.org, or send a letter to:
725 6th Street NW
Albuquerque, NM 87102
*This Privacy Statement was last updated on September 4, 2017.
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